PRIVACY POLICY

UPDATED NOVEMBER 1ST 2017

Comencia is dedicated to making your Smart City experience the best it can be. As such, it is important to us that you feel comfortable when you use our service. This Privacy Policy is provided to answer any questions you may have about the information we collect when you use our service, why we collect it, and how we may use and disclose it to others. We define “Service” as the websites and mobile applications on which we display this Privacy Policy, as well as the functionality we make available through those websites. By using our Service, you are indicating to us that you agree to our collection, use and disclosure of your information, as described in this Privacy Policy.

WHAT INFORMATION DO WE COLLECT FROM YOU?

REGISTERING WITH COMENCIA

When you register for our service and create a User Profile, you will be required to provide an email address and select a password.

YOUR SMART CITY PROFILE

You have the option of providing additional information in your Smart City profile that includes:

• Your address
• A mobile phone number
• A paragraph about you
• Work experience
• Skills
• Education
• Social media accounts
• Interests
• Preferences
• Custom attributes

SEARCHING AND BOOKING TRAVEL

We receive and store information you enter on our Travel website. This includes information that can identify you (“personal information”), including your first and last name, telephone number, postal and email addresses. We may also request information about your hotel room preferences. We NEVER store Credit Card information in our records. You can choose not to provide information to us, but in general some information about you is required in order for you to book travel and initiate transactions through our site. When you make a reservation for someone else through this website we may request personal information and travel preferences about that individual. You should obtain the consent of other individuals prior to providing us with their personal information and travel preferences, as any access to view or change their information will be available only through your account.

DINING SITES

We receive and store any information you enter on our Smart.Menu websites. This includes personal information that can identify you including your first and last name, telephone number, postal and email addresses. We may also request information about your dietary preferences. We NEVER store Credit Card information in our records. You can choose not to provide information to us, but in general information about you is required in order for you to reserve tables, order food or initiate other transactions on our site. When you make a reservation or place an order for someone else through this website, we may request personal information and dietary preferences about that individual. You should obtain the consent of other individuals prior to providing us with their personal information and preferences, as any access to view or change their information will be available only through your account.

SHOPPING SITES

We receive and store any information you enter on our .SHOP websites. This includes personal information that can identify you, including your first and last name, telephone number, postal and email addresses. We may also request information about your shopping preferences. We NEVER store Credit Card information in our records. You can choose not to provide information to us, but in general some information about you is required in order for you to make online purchases or initiate other transactions on our site.

LEGAL DIRECTORY AND LEGAL PROVIDER SITES

We do not store any information related to legal provider sites.

COMMUNITY INSTANT SUPPORT (CIS)

We store information regarding the questions you post through our peer-to-peer chat function, as well as the number of questions you answer, the answers you provide and the feedback you receive on the quality of the answers. You have the choice to operate anonymously on our CIS service.

COMMUNICATION.

When you communicate with us via email or our contact form on our sites, we will collect your email address and store the contents of the communication.

AUTOMATIC COLLECTION OF INFORMATION.

We automatically collect some information about your computer when you visit any of our websites or use our Apps. For example, we will collect your IP address and Web browser software (such as Firefox, Safari, or Internet Explorer). We also may collect information about your online activity, such as trips viewed and bookings made. Our goals in collecting this automatic information include helping customize your user experience and inhibiting fraud.

COOKIES.

When you use our Service we may send one or more cookies to your computer or your mobile device. We use both “session” and “persistent” cookies. Session cookies are temporary and are erased when you close your browser. When you restart your browser and go back to the site that created the cookie, the website will not recognize you. Persistent cookies stay in one of your browser’s subfolders until you delete them manually or your browser deletes them based on the duration period contained within the persistent cookie’s file.

DEVICE PROVIDED INFORMATION.

Accessing our service from your mobile device means your mobile device will make certain information available which may include personally identifiable information. We may choose to collect this information and disclose it as described in this policy.

CREDIT CARD INFORMATION

Although there will be times we ask you for credit card information, we do not store this information in our records. There will be times where we use third party payment processors to store this information in a very secure environment that our systems can access through highly secure channels for the completion of transactions you subsequently initiate.

HOW DO WE USE THE INFORMATION?

We use information we collect to ensure we provide you with a great user experience. Examples of how we may use the information include:

• We may pass your dietary preferences to a restaurant to allow them to offer you a tailored menu.
• We pass your mailing address to our eCommerce partners so you don’t have to type in your shipping information.
• We may pass your address to our Travel application to reduce the amount of information you need to provide each time you book travel.
• We may use the information to update you on new features or functionality introduced on our website. You always have the option of opting out of emails.
• In the event of any security, privacy or administrative issues relating to the use of the service, we may contact you via email or another form of electronic notification.

HOW LONG DO WE STORE IT?

information on your profile page can be updated by you at any time. We store it as long as you are a registered user on the platform.

IS INFORMATION SHARED OR DISCLOSED?

Comencia may provide personally identifiable information to third parties for their use in helping us perform our internal business functions. These include:

• When you create a smart wallet we will collect your payment details and store them securely with a PCIDSS Certified (Payment Card Industry Data Security Standard) third party. No credit card information will be stored in Comencia’s records.
• When you withdraw funds from a smart wallet, our third party payment partner will collect and securely store your bank, PayPal or mailing address (Paper Check) details in order to facilitate the withdrawal. Our payment processing partner may request you provide certain personal data (e.g., a valid government issued ID, your legal name, address, and data of birth) for the purpose of making payment through its financial institutions and complying with any federal and state laws and regulations. They may also communicate directly with you regarding any issues with a payment.

If you book travel with Comencia we will provide the payment details you give us to our Suppliers, such as hotels, airlines, car rentals, and activity providers, who fulfill your travel reservations. We do not place limitations on our suppliers’ use or disclosure of your other personal information. Therefore, we encourage you to review the privacy policies of any travel supplier whose products you book through this site. Please note these suppliers also may contact you as necessary to obtain additional information about you, facilitate your travel reservation, or respond to a review you may submit.

If you reserve a restaurant table or order food through our Smart.Menu platform, we will provide your Name, Address, Email Address and Cell Phone number to the restaurant. Please note these service providers also may contact you as necessary to obtain additional information about you, facilitate your reservation, order, or respond to a review you may submit.

If make a purchase through the Smart.Shop platform we will provide your Name, Address, Email Address and Cell Phone number to the restaurant. Please note these service providers also may contact you as necessary to obtain additional information about you to facilitate your purchase.

If you Single Sign On from a Third Party Application or Website we will provide your Name and a unique reference number that identifies you as a Comencia user. You will be prompted to select the information that you wish to supply to the third party from the list below:

• Your address
• Cell phone number
• Social media links
• Interests
• Preferences
• Additional custom attributes

We will do our very best to require these third parties to maintain your information securely, to ensure they do not use it for purposes other than providing services to us, and to refrain from disclosing the information except when required by law. We may disclose your information if required to do so by law or in good faith, we believe disclosure is necessary in order to:

• satisfy legal obligations or comply with legal process (such as a subpoena) served on Comencia;
• take action on user complaints,
• investigate and defend Comencia against any legal claims or threats;
• protect Comencia and others from fraudulent, abusive, predatory, or unlawful uses or activity;
• protect and defend the rights or property of Comencia; or
• act in urgent circumstances to protect the personal safety of users of Comencia, the Service, or the Public.

If there is a change in ownership of Comencia, whether through a merger with, acquisition by, or sale of assets to another entity, we may sell or otherwise transfer the information you provide to us, which will include personally identifiable information, to that entity.

Comencia may disclose aggregated, anonymized, or other types of non-personally identifiable information, including “automatically collected” information.

Our servers and data centers are located in the United States. Your personal information is therefore transferred to the United States and will be protected in accordance with the “Security” section below.

RIGHT TO WITHDRAW CONSENT

Consent is collected and recorded when you sign up for a Comencia account. You have the right to withdraw consent at any time. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal. You can withdraw content by emailing support@comencia.com

RIGHT TO SUSPEND YOUR ACCOUNT

You have the right to suspend your account at any time by emailing support@comencia.com

SECURITY

We take security very seriously and we employ various physical, process and technical safeguards designed to help protect the security and integrity of our systems and to protect us against the lost, misuse or alteration of personally identifiable information we control.

We perform regular vulnerability assessment scans using an accredited third party specialist.

Comencia complies with all relevant security legislation including, but not limited to:

• EU GDPR (EU General Data Protection Regulation)
• PCI-DSS 3.0 (Payment Card Industry Data Security Standards)
• 18 U.S.C. § 1028A – Aggravated identity theft
• 18 U.S.C. § 1029 – Fraud and related activity in connection with access devices
• 18 U.S.C. § 1030 – Fraud and related activity in connection with computers
• 18 U.S.C. § 1037 – Fraud and related activity in connection with electronic mail
• Controlling the Assault of Non- Solicited Pornography and Marketing Act of 2003 CAN-SPAM Act (15 USC 7701 et seq.)
• Section 404, Sarbanes-Oxley Act of 2002 (SOX) or Public Company Accounting Reform and Investor Protection Act
• Federal Privacy Act of 1974

Even though we take reasonable measures to protect your information, we do not guarantee the security of your information. If we learn of a security systems breach that affects your information, we will notify you electronically either via email or our website so that you can take appropriate steps to protect yourself.

Comencia retains the right to decide which method we will use to notify you of a security breach and will do so consistent with our legal obligations.

DATA CONTROLLER / DATA PROTECTION OFFICER

You can contact our data controller or data protection officer by emailing support@comencia.com

EXTERNAL LINKS

If any part of this website links you to other sites, those sites do not operate under this Privacy Policy. We recommend you examine the privacy statements posted on those other websites to understand their procedures for collecting, using, and disclosing personal information.

DO NOT TRACK (DNT)

Comencia does not currently respond to browser DNT signals on its websites or online services.

CALIFORNIA PRIVACY RIGHTS

You may have the rights to receive a copy of the personal information Comencia holds about you, and/or information identifying any third party company or companies to which Comencia may have disclosed personally identifying information pertaining to you. You also have the right to receive a description of the categories of personally identifiable information that may have been disclosed. Please make requests in writing to:

Compliance Department Comencia PLC Suite 801, 10655 NE 4th St., Bellevue, WA 98004

CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy in the future. If you have registered as a member on our site, we will notify you about material changes to this Privacy Policy by sending a notice to the email address you provided to us.

If you have questions about this Privacy Policy please email support@comencia.com